env compliance guide

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COMPLIANCE

E N V I R O N M E N T A L

South Carolina Department of Health and Environmental Control

Center for Waste MinimizationWWW.SCDHEC.GOV/CWM

A Handy Guide for

November 2006

Printed on RECYCLED Paper OR-0639 11/06


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Introduction

It is important for everyone to comply with environmental regulations in order to protectthe health of both humans and the natural resources that we all depend on. Anotherreason to comply with environmental regulations is to avoid potentially costly penalties

associated with non-compliance. Environmental regulations may seem confusing anddaunting but having a proper understanding of them and how your business affects theenvironment may actually allow you to save money and be more productive. Forexample, best management practices (BMPs) will make environmental complianceeasier and less costly. Pollution Prevention (P2) is another way to increase compliancewhile reducing costs. It involves replacing toxic or hazardous products with environmentand employee friendly materials, equipment and process modifications to reduce thegeneration of waste, and improved operations and maintenance (including employeetraining).

This environmental compliance assistance guide contains step-by-step self auditchecklists and surveys to determine trends towards compliance or non-compliance withSouth Carolinas laws and regulations on waste disposal, underground storage tanks,wastewater, storm water, and air pollution. We have tried to make it clear and concisebut with enough detail so that many or most of your questions will be answered righthere. However, if you need more help please contact the appropriate SC DHEC Bureau.Contact numbers are provided in the next section. Another option is to contact either theSmall Business Environmental Assistance Program (1-800-819-9001) or the Center forWaste Minimization (803-896-8986).

This guide and all associated materials were prepared to aid the regulated communityin evaluating their compliance with environmental requirements arising under federaland state law. The statements in this document are intended solely as guidance.This document is not intended, nor can it be relied on, to create any rights

enforceable by any party in litigation with the United States or the state of SouthCarolina. Every effort has been made to ensure the accuracy of the statements inthis document; however, the regulated entitys legal obligations are determined by theterms of its applicable environmental facility-specific permits, and underlying statutesand applicable state and local law. Nothing in this document alters any statutory,regulatory or permit requirement. In the event of a conflict between statements in thisdocument and either the permit or the regulations, this document would not becontrolling. Completing this checklist is intended to provide insight to the importanceDHEC places on environmental regulations. This checklist is meant to helphighlight what is required for compliance, but does not assure compliance.

The Center for Waste Minimization is available to assist in filling out any of the self-auditchecklists or surveys, if requested, and can help in your appraisal of your likelycompliance status. The checklists/surveys will remain at your facility, and containedinformation will not be made available to DHECs regulatory staff.

The Center for Waste Minimization also is prepared to assist you in minimizing theamount of wastes that you generate, which may lead to regulatory control. A free, non-


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regulatory waste assessment can identify options to reduce or eliminate these wastestreams. If wastes are not generated, they cannot be regulated.

If you are interested in receiving assistance from the Center, please contact them at:

Center for Waste Minimization

SC Department of Health and Environmental Control2600 Bull StreetColumbia, SC 29201(803) 896-8986(803) 896-8991Online at www.scdhec.gov/cwm
http://www.scdhec.gov/cwmhttp://www.scdhec.gov/cwm


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Table of Contents

IntroductionAdditional Sources of InformationDHEC Environmental Quality Control Regional Offices

List of Acronyms

Section A: Water Guidance and ChecklistsWastewaterStorm WaterEPA Definition of No Exposure in Storm Water PermittingEleven Industrial Categories requiring NPDES PermitsSelf Operation & Maintenance Evaluation Survey for POTWs

Section B: Air Guidance and Checklist

Section C: Underground Storage Tank Guidance and Checklist

Section D: Solid and Hazardous Waste Guidance and ChecklistConditionally Exempt Small Quantity GeneratorsSmall Quantity GeneratorsLarge Quantity GeneratorsUniversal Waste Handlers

Appendix I: Maximum Concentrations of Contaminants for the ToxicityCharacteristic

Appendix II: Hazardous Wastes from Non-Specific SourcesAppendix III: Hazardous Wastes from Specific SourcesAppendix IV: Hazardous Wastes form Discarded MaterialsAppendix V: Acutely Hazardous Wastes from Discarded MaterialsAppendix VI: SCHWMR Citations not in 40 CFR


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Additional Sources of Information

DHEC General Contact:2600 Bull StreetColumbia, SC 29201

(803) 898-3432

Air Quality-Bureau of Air Quality (BAQ)..... (803) 898-4123

Online: http://www.scdhec.gov/baq-Air Quality Fact Sheets: http://www.scdhec.gov/eqc/baq/html/baq_facts.html#-Plain English Guide to the Clean Air Act (EPA-400-K-93-001):

http://www.epa.gov/oar/oaqps/peg_caa/pegcaain.html-EPA List of Air Pollutants:http://www.epa.gov/ebtpages/airairpollutants.html

Solid and Hazardous Waste-Bureau of Land and Waste Management (BLWM)...... (803) 896-4001

Online: http://www.scdhec.gov/lwm-EPA's toll-free RCRA/Superfund Hotline.............. (800) 424-9346-EPA National Waste Minimization Program: http://www.epa.gov/wasteminStorm Water and Wastewater-Bureau of Water (BOW).... (803) 898-4215

Online: http://www.scdhec.gov/water/-NPDES Overview for Industrial and Commercial Facilities:

http://cfpub.epa.gov/npdes/home.cfm?program_id=14-Guidance Manual for Conditional Exclusion from Storm Water Permitting Based On NoExposure of Industrial Activities to Storm Water (EPA 833-B-00-001):

http://www.scdhec.gov/eqc/water/pubs/noxguide.pdf-National Menu of Best Management Practices for Storm Water Phase II:

http://cfpub.epa.gov/npdes/stormwater/menuofbmps/menu.cfm- Summary Guidance for Developing Pollution Prevention Plans and Best ManagementPlans for Industrial Activities (EPA 833-R-92-002)-EPA Storm Water Program (lots of fact sheets in the publication section):

http://cfpub.epa.gov/npdes/home.cfm?program_id=6

Underground Storage Tanks-SC DHEC, Underground Storage Tanks (Help Line, Assistance and Leak Reporting)

Online: http://www.scdhec.gov/ust/ . . . . . . . . . . . . . . . . . . . . . . . (803) 896-7957-EPA, A Basic Checklist for USTs: http://epa.gov/swerust1/cmplastc/cheklist.htm-EPA UST FAQs: http://www.epa.gov/swerust1/faqs/index.html-Operating and Maintaining Underground Storage Tank Systems: Practical Help andChecklists: http://www.epa.gov/swerust1/pubs/ommanual.html-Musts for USTs: A Summary of the Federal Regulations for Underground Storage TankSystems: http://www.epa.gov/swerust1/pubs/musts.html
http://www.scdhec.gov/baqhttp://www.scdhec.gov/baqhttp://www.scdhec.gov/eqc/baq/html/baq_facts.htmlhttp://www.epa.gov/oar/oaqps/peg_caa/pegcaain.htmlhttp://www.epa.gov/ebtpages/airairpollutants.htmlhttp://www.scdhec.gov/lwmhttp://www.scdhec.gov/lwmhttp://www.epa.gov/wastemin/http://www.scdhec.gov/water/http://www.scdhec.gov/water/http://cfpub.epa.gov/npdes/home.cfm?program_id=14http://www.scdhec.gov/eqc/water/pubs/noxguide.pdfhttp://cfpub.epa.gov/npdes/stormwater/menuofbmps/menu.cfmhttp://cfpub.epa.gov/npdes/home.cfm?program_idhttp://www.scdhec.gov/ust/http://epa.gov/swerust1/cmplastc/cheklist.htmhttp://www.epa.gov/swerust1/faqs/index.htmlhttp://www.epa.gov/swerust1/pubs/ommanual.htmlhttp://www.epa.gov/swerust1/pubs/musts.htmlhttp://www.epa.gov/swerust1/pubs/musts.htmlhttp://www.epa.gov/swerust1/pubs/ommanual.htmlhttp://www.epa.gov/swerust1/faqs/index.htmlhttp://epa.gov/swerust1/cmplastc/cheklist.htmhttp://www.scdhec.gov/ust/http://cfpub.epa.gov/npdes/home.cfm?program_idhttp://cfpub.epa.gov/npdes/stormwater/menuofbmps/menu.cfmhttp://www.scdhec.gov/eqc/water/pubs/noxguide.pdfhttp://cfpub.epa.gov/npdes/home.cfm?program_id=14http://www.scdhec.gov/water/http://www.epa.gov/wastemin/http://www.scdhec.gov/lwmhttp://www.epa.gov/ebtpages/airairpollutants.htmlhttp://www.epa.gov/oar/oaqps/peg_caa/pegcaain.htmlhttp://www.scdhec.gov/eqc/baq/html/baq_facts.htmlhttp://www.scdhec.gov/baq


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Other Resources-Center for Waste Minimization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (803) 896-8986

Online: http://www.scdhec.gov/cwm-Small Business Environmental Assistance Program (SBEAP) . . . . . . . . .(800) 819-9001

Online:http://www.scdhec.gov/sbeap

-SC DHEC Online Forms: http://www.scdhec.gov/eqc/admin/html/eqforms.html-Compliance Assistance online: http://www.scdhec.gov/compass-EPA Compliance Assistance . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . (202) 564-2310

Online:http://www.epa.gov/compliance/assistance/index.htmlNOTE: EPA Publications can be obtained in several different ways. The first is to go toEPAs website at http://www.epa.gov/ncepihom/ordering.html to order, read, ordownload documents online. You can also write and ask for free publications byaddressing your request to EPAs publication distributor: National Service Center forEnvironmental Publications (NSCEP), Box 42419, Cincinnati, OH 45242. You may alsocontact EPAs publication distributors toll-free number at (800) 490-9198 or fax (513)489-8695.
http://www.scdhec.gov/cwmhttp://www.scdhec.gov/cwmhttp://www.scdhec.gov/sbeaphttp://www.scdhec.gov/sbeaphttp://www.scdhec.gov/eqc/admin/html/eqforms.htmlhttp://www.scdhec.gov/compasshttp://www.epa.gov/compliance/assistance/index.htmlhttp://www.epa.gov/compliance/assistance/index.htmlhttp://www.epa.gov/ncepihom/ordering.htmlhttp://www.epa.gov/ncepihom/ordering.htmlhttp://www.epa.gov/compliance/assistance/index.htmlhttp://www.scdhec.gov/compasshttp://www.scdhec.gov/eqc/admin/html/eqforms.htmlhttp://www.scdhec.gov/sbeaphttp://www.scdhec.gov/cwm


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DHEC Environmental Quality Control ( EQC)Regional Offices

If you would like to contact someone locally, DHEC Environmental Quality Control RegionalOffices would be a good place to start.

Region 1

Anderson EQC Office2404 N. Main StreetAnderson, SC 29621-3275Anderson, Oconee Counties...... ( 864) 260-5569

Greenwood EQC Office613 South Main StreetGreenwood, SC 29646-3245Abbeville, Edgefield, Greenwood, Laurens, McCormick, Saluda Counties(864) 223-0333

Region 2

Greenville EQC Office301 University Ridge, Suite 580Greenville, SC 29601-3677Greenville, Pickens Counties.. (864) 241-1090

Spartanburg EQC Office975- C North Church StreetSpartanburg, SC 29303-2712Cherokee, Union, Spartanburg Counties...(864) 596-3800

Region 3

Columbia EQC OfficeP.O. Box 156State Park, SC 29147-0156Fairfield, Lexington, Newberry, Richland Counties...... (803) 896-0620

Lancaster EQC OfficeP.O. Box 100Lancaster, SC 29720Chester, Lancaster, York Counties....... (803) 285-7461

Region 4

Florence EQC Office

145 E. Cheves StreetFlorence, SC 29506-2526Chesterfield, Darlington, Dillon, Florence, Marion, Marlboro Counties(843) 661-4825

Sumter EQC OfficeP.O. Box 1628Sumter, SC 29151Clarendon, Kershaw, Lee, Sumter Counties............. (803) 778-6548


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Region 5

Aiken EQC Office206 Beaufort Street, NEAiken, SC 29801-4476Aiken, Allendale, Bamberg, Barnwell, Calhoun, Orangeburg Counties. (803) 641-7670

Region 6

Myrtle Beach EQC Office927 Shine AvenueMyrtle Beach, SC 29577-3580Georgetown, Horry, Williamsburg Counties..... (843) 238-4378

Region 7

Charleston EQC Office1362 McMillan Ave., Suite 300Charleston, SC 29405Berkeley, Charleston, Dorchester Counties..... (843) 740-1590

Region 8

Beaufort EQC Office104 Parker DriveBurton, SC 29906Beaufort, Colleton, Hampton, Jasper Counties....... (843) 846-1030


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112(r) accidental release prevention require-

ment section of the Clean Air Act

ARAR Applicable or Relevant and Appropri-

ate Requirements

AST Above Ground Storage Tank

BACT Best Available Control Technology

BAQ Bureau of Air Quality (DHEC)BDAT Best Demonstrated Available (or

Achievable) Technology

BIFs Boilers and Industrial Furnaces

BLWM Bureau of Land & Waste management

(DHEC)

BMP Best Management Practices

BMR Baseline Monitoring Report

BOD Biochemical Oxygen Demand

BOW Bureau of Water (DHEC)

BRAP Business Recycling Assistance Pro-

gramC&D Construction and Demolition

CAA Clean Air Act

CAMEO Computer-Aided Management Of

Emergency Operations

CAS Chemical Abstracts Service

CBEP Community Based Environmental

Protection

CBI Confidential Business Information

CEMS Continuous Emission Monitoring Sys-

tem

CEPPO Chemical Emergency Preparednessand Prevention Office

CERCLA Comprehensive Environmental Re-

sponse, Compensation, and Liability

Act

CESQG Conditionally Exempt Small Quantity

Generator

CFC Chlorofluorocarbons

CFR Code of Federal Regulations

CIB Chemical Industry Branch

CMA Chemical Manufacturers Association

COE U.S. Army Corps of EngineersCWA Clean Water Act

CWM Center for Waste Minimization (DHEC)

DHEC Department of Health & Environmen-

tal Control

DMR Discharge Monitoring Report

DOC Department of Commerce

DOT Department of Transportation

E2SC Environmental Excellence in South

Carolina

EHS Extremely Hazardous Substance (list

of 356 chemicals)

ELG Effluent Limitation Guidelines

EMD Emergency Management Division

EMS Environmental Management System

EPA US Environmental Protection Agency

EPCRA Emergency Planning and CommunityRight-to-Know Act of 1986

EQC Environmental Quality Control

ERT Emergency Response Team (DHEC)

ESA Endangered Species Act

FEP Federal, Energy & Pretreatment (Per-

mitting Section)

FIFRA Federal Insecticide, Fungicide, and

Rodenticide Act

FMEA Failure Mode and Effects Analysis

FORM R document used to report annual re-

leases of certain chemicals (list of 650chemicals)

FR Federal Register

FRP Fiberglass-Reinforced Plastic

FTA Fault Tree Analysis

FWPCA Federal Water Pollution Control Act

GIS Geographic Information System

GPO U.S. Government Printing Office

GWPD Ground-Water Protection Division

HAP Hazardous Air Pollutant

HAZOP HAZard and OPerability study

HAZWOPER HAZardous Waste OPerations andEmergency Response (29 CFR part

120)

HCS Hazard Communication Standard

HHW Household Hazardous Waste

HMTA Hazardous Materials Transportation

Act

HSWA Hazardous and Solid Waste Amend-

ments of 1984

ICP Integrated Contingency Plan

LAER Lowest Achievable Emission Rate

LDRs Land Disposal RestrictionsLEPC Local Emergency Planning Committee

LERC Local Emergency Response Commis-

sion

LFL Lower Flammability Limit

LQG Large Quantity Generator

MACT Maximum Achievable Control Technol-

ogy

MCL Maximum Contaminant Level

MCLG Maximum Contaminant Level Goal

List of Commonly Used Acronyms

Acronym Term Acronym Term


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MGD Million Gallons per Day

MOC Management Of Change

MS4 Municipal Separate Storm Sewer

System

MSDS Material Safety Data Sheet

MSW Municipal Solid Waste

NAAQS National Ambient Air Quality Standard

NACD National Association of Chemical Dis-tributors

NAICS North American Industry Classification

System

NCP National Contingency Plan

NESHAP National Emissions Standards for

Hazardous Air Pollutants

NFPA National Fire Protection Association

NPDES National Pollutant Discharge Elimina-

tion System

NPL National Priorities List

NPS Non Point SourceNRC National Response Center

NRT National Response Team

NSPS New Source Performance Standards

O&M Operations & Maintenance

OCA Offsite Consequence Analysis

OCRM Ocean and Coastal Resource Man-

agement

OECA Office of Enforcement and Compli-

ance Assurance

OEPPR Office of Emergency Prevention, Pre-

paredness and ResponseOP Operating Permit

OPPTS Office of Pollution Prevention and

Toxic Substances

OSHA Occupational Safety and Health Act

OSHA Occupational Safety and Health Ad-

ministration

OSW EPA Office of Solid Waste

OSWER EPA Office of Solid Waste and Emer-

gency Response

P&IDs Piping and Instrumentation Diagrams

P.E. Professional EngineerP2 Pollution Prevention

P3 Pollution Prevention Plan

PA/SI Preliminary Assessment and Site

Inspection

PCA Pollution Control Act of South Carolina

PER Preliminary Engineering Report

PFD Process Flow Diagrams

PHA Process Hazard Analysis

PM 10 Particulate Matter (diameter of 10

micrometers or less)

PM 2.5 Particulate Matter (diameter of 2.5

micrometers or less)

POTW Publicly Owned Treatment Work

PPA Pollution Prevention Act

PRP Potentially Responsible Party

PS Point Source

PSD Prevention of Significant Deterioration

psi Pounds per Square InchPSM Process Safety Management (29 CFR

1910.119)

QC Quality Control

RCRA Resource Conservation and Recovery

Act

RI/FS Remedial Investigation/Feasibility

Study

RMP Risk Management Plan

RMP Risk Management Program

RMP comp software program used to calculate

the approximate area a chemicalrelease might impact

RMP SUBMIT Software program used to summarize

a facilities Risk Management program

ROD Record of Decision

RQ Reportable Quantity

SARA Superfund Amendments and Reautho-

rization Act

SBEAP Small Business Environmental Assis-

tance Program (DHEC)

SC DHEC South Carolina Department of Health

& Environmental ControlSCHWMR South Carolina Hazardous Waste

Management Regulations

SCUSTCR South Carolina Underground Storage

Tank Control Regulations

SDWA Safe Drinking Water Act

SEP Supplemental Environmental Projects

SERC State Emergency Response Commis-

sion

SIC Standard Industrial Classification

SOCMA Synthetic Organic Chemical Manufac-

turers AssociationSOP Standard Operating Procedures

SPCC Spill Prevention, Control, and Coun-

termeasures (40 CFR part 112)

SQG Small Quantity Generator

STP Sewage Treatment Plant OR Standard

Temperature and Pressure

SUPERB State Underground Petroleum Envi-

ronmental Response Bank

SW Storm Water

SWDA Solid Waste Disposal Act


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SWIX Southern Waste Information eX-

change

SWMU Solid Waste Management Unit

TCLP Toxicity Characteristic Leaching Pro-

cedure

TIER II Document used to report annual

chemical inventories at a facility

TIER II SUBMITSoftware program to generate a Tier IIdocument

TMDL Total Maximum Daily Load

TPQ Threshold Planning Quantity

TPY Tons Per Year

TQ Threshold Quantity

TRI Toxic (Chemical) Release Inventory

TRI-ME Toxic Chemical Release Inventory

Made Easy, software program used to

generate a FORM R document

TSCA Toxic Substance Control Act

TSDF Treatment, Storage, and Disposal

Facility

TSDR Treatment, Storage, Disposal, and

Recycling (Facility)

TSP Total Suspended Particulates

TSS Total Suspended Solids

U.S.C. United States CodeUIC Underground Injection Control

UST Underground Storage Tank

VOC Volatile Organic Compound

WTP Water Treatment Plant

WV Weighted Value

WWTP Waste Water Treatment Plant


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Wastewater Regulatory Requirements

Wastewater discharges are regulated by DHECs Bureau of Water (BOW). Wastewaterdischarges from chemical industries include sanitary wastewater from bathrooms andsinks and process wastewaters from floor cleaning, equipment cleaning, and other

sources. How wastewater discharges from your facility are regulated is dependent uponwhether the wastewater is being discharged to:

-a municipal wastewater treatment plant,-a septic system,-the surface of the ground or surface waters.

How discharges are regulated also depends on the volume of the discharge and whetherit is sanitary wastewater, process wastewater (e.g. from floor drains, etc.) or acombination of both sanitary and process wastewater.

Discharges to Municipal Sewer Systems

Facilities that discharge non-sanitary wastewater (e.g. floor drain wastewater, spentaqueous parts cleaning solutions, etc.) to a wastewater treatment plant should notify theBureau of Water and the local treatment facility to obtain written approval for thedischarge. This allows the wastewater treatment plant to verify that the contaminants inyour wastewater are compatible with their system and can be adequately treated there.The wastewater treatment plant may be able to accept your wastewater as it is but it isalso possible that your wastewater will need to be pretreated. If a pretreatment permit isissued by the municipality, then a DHEC wastewater construction permit may berequired for any treatment system that needs to be built to meet the limitations set by thesewer authority, including simple systems such as an oil/water separator. Prior tooperating any wastewater pretreatment system, operational approval must be granted bythe local DHEC EQC office. If pretreatment is not required and the sewer authoritygrants permission for the discharge, you may still need a construction permit andoperating approval from DHEC for the sewer line connecting the discharge to the sewerlines already in existence. Hazardous materials, such as parts cleaning solvents, oils, orpainting wastes are generally prohibited from being discharged to the sewer.

Pump and Haul

If the wastewater treatment facility cant or wont accept your wastewater then you maychoose to manage it another way such as containerization using pump and haul. Usingthis method, you will locate a suitable disposal facility, whether it is a municipal,industrial, or other centralized waste treatment facility, and obtain their approval toaccept your wastewater. Pumping and hauling of wastewater may also require approvalfrom the Bureau of Water depending on the volume and frequency of disposal.


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Septic System

If a municipal sewer is not available, a septic system may be considered for yourwastewater discharges. Septic tanks should really only be used for sanitarywastewater. You may contact the local Environmental Quality Control office of yourcounty for assistance (see the listing of DHECs Regional Offices). If the discharged

wastewater includes process wastewater, the county environmental health office willwork along with the Bureau of Water to determine the appropriate permit needs for yourlocation. You may be asked to consider a different method of wastewater disposal suchas containerization or pump and haul methods.

Although it may be possible for a business to obtain a permit to discharge processwastewater on-site under limited circumstances, the potential liability of such a practiceshould be given serious consideration. If nearby persons depend on groundwater fordrinking, there is the potential for contamination of a well. The Department stronglydiscourages the combination of domestic and non-domestic discharges to on-sitesubsurface disposal systems. In any event, approval must be obtained from DHEC priorto the discharge of non-domestic wastewater to an on-site subsurface disposal system.

Discharges of Wastewater to the Ground or Surface Water

Discharges of wastewaters to either the ground or to surface waters require a permitfrom the Bureau of Water. Discharges to the ground may be in the form of discharges toa pond or wastewater lagoon or land application of the wastewaters by spraying themonto the ground surface via an irrigation system or mobile method. In these situations,the Department is concerned with the potential impacts to the groundwater quality nearthese sites and limiting runoff from these sites. A land application or no discharge (ND)permit may be issued for these types of wastewater disposal with limitations designed toprotect the groundwater.

Discharges to surface waters, including storm drains that discharge to surface waters,require an NPDES permit. This permit will contain limitations to protect both humanhealth and aquatic life based on the nature of the discharges, whether sanitary orprocess or a combination of discharges, the size of the stream to which the dischargeflows, and various other factors. If another suitable means of wastewater disposal isavailable, such as those discussed above, an NPDES permit may not be granted to adischarger.

In either the ground or surface water disposal methods, quite often a treatment system isneeded to meet the limitations set in the permit. A wastewater construction permit andoperating approval must be obtained prior to placing a system or any modifications to an

existing system into operation.


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NPDES Wastewater Checklist

If you answerYes orNA (non applicable) to all of the questions in this section then you are on the right track to

being in compliance. However, if you answerNo to any of the questions you may not be complying with all of the

requirements under South Carolina and Federal Environmental Laws and Regulations. If you need help determin-

ing how to come into compliance, there is a list of additional information and bureau contacts at the end of this

section.

1. We are aware of what processes in our facility generate wastewater. Yes/NA No

2. We know where our wastewater is discharged (e.g., released to public sewer, Yes/NA No

septic tank/tile field, storm drain, pump and haul, etc.).

3. We have identified all of the floor drains in our facility and know where they Yes/NA No

discharge to. (Floor drains that are not connected to a permitted wastewater

treatment plant are prohibited.)

4. We do not dispose of any hazardous materials through our sinks or drains. Yes/NA No

5. Our facilitys wastewater discharges to a public sewer and we have received Yes/NA No

approval from DHEC and the local sewer authority for the discharge. If required,

we pretreat our wastewater and have met all the requirements of doing so

(e.g., an industrial pretreatment permit, a DHEC wastewater construction permit

and operating approval and proper sludge disposal methods).

OR

Our facilitys wastewater is containerized and/or pumped and hauled to remove

it from our facility. We have met all requirements that may be associated with

transporting our wastewater.

OR

We use another method to dispose of wastewater and have checked with our

regulatory agency for the appropriateness of this method and any permitting

needs associated with it.

6. We discharge sanitary wastewater (domestic wastewater) to an on-site subsurface Yes/NA No

system (i.e. septic system) and have received a septic tank permit from DHECs

Environmental Health Office.

7. We use a DHEC approved lab for any required sampling. Yes/NA No

8. We maintain all required records on-site. Yes/NA No


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Storm Water Regulatory Requirements

Activities that take place at industrial facilities, such as material handling and storage,are often exposed to storm water. The runoff from these activities discharges industrial

pollutants into nearby storm sewer systems and water bodies. This may adverselyimpact water quality.

To limit pollutants in storm water discharges from industrial facilities, the NationalPollutant Discharge Elimination System (NPDES) Storm Water Program includes anindustrial storm water permitting component. Operators of industrial facilities that havestorm water discharges associated with industrial activity that discharge storm water to amunicipal separate storm sewer system (MS4) or directly to waters of the United Statesrequire authorization under a NPDES industrial storm water permit. Chemical and alliedproduct manufacturers are deemed to have storm water discharges associated with theiractivities and NPDES permits are requiredfor such discharges.

In some cases, a facility operator may be eligible for a conditional/temporary exclusionfrom permitting requirements. Otherwise, the facility operator must determine if thefacility is eligible for coverage under a general or an individual NPDES industrial stormwater permit. Most industrial facilities have permit coverage under a general permitbecause it is the most efficient permit option. General permits contain requirements fornumerous types of industrial activities, allowing a facility operator to quickly obtain permitcoverage. However, there are certain circumstances where a general permit is eithernot available or not applicable to a specific facility. In this type of situation, a facilityoperator must obtain coverage under an individual permit that the NPDES permittingauthority will develop with requirements specific to the facility.


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NPDES Storm Water Checklist

The storm water checklist is based on whether or not you have any materials or activities exposed to precipitation

that require permitting. If you know whether or not you qualify for no exposure exemption, then please proceed

to the appropriate checklist: No Exposure,General Permit, and Individual Permit. If you do not know what your

status is, then please complete the exposure status checklist first. (You may also find the EPA definition of no

exposure at the end of this section to be of use.) Follow the directions at the end of the exposure status checklist

to determine if you should then complete the No Exposure,General Permit, and Individual Permitchecklist.

In the No Exposure,General Permit, and Individual Permitsections, if you answerYes orNA (non applicable) to

all of the questions then you are on the right track to being in compliance. However, if you answerNo to any of

the questions you may not be complying with all of the requirements under South Carolina and Federal Environ-

mental Laws and Regulations. If you need help determining how to come into compliance, there is a list of addi-

tional information and Bureau contacts at the end of this section.

NPDES Storm Water Checklist: Exposure Status

Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future?

1. Using, storing, or cleaning industrial machinery equipment, and areas where resid-

uals from using, storing or cleaning industrial equipment remain and are exposed

to storm water.

2. Materials or residues on the ground or in storm water inlets from spills/leaks.

3. Materials or products from past industrial activity.

4. Material handling equipment (except adequately maintained vehicles).

5. Materials or products during loading/unloading or transporting activities.

6. Materials or products stored outdoors (except final products intended for outside

use [e.g., new cars] where exposure to storm water does not result in the dis-

charge of pollutants).

7. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks,

and similar containers.

8. Materials or products handled/stored on roads or railways owned or maintained by

the discharger.

9. Waste material (except waste in covered, non-leaking containers [e.g., dumpsters]).

10. Application or disposal of process wastewater (unless otherwise permitted).

11. Particulate matter or visible deposits of residuals from roof stacks and/or vents

not otherwise regulated (i.e., under an air quality control permit) and evident in the

storm water outflow.

If you answered No to every question in this section then please proceed to the No Exposure Certification check-

list. If you answered Yes to any of the questions in this section you are not eligible for the no exposure certifica-

tion. Please proceed to the General Permitchecklist.

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No


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NPDES Storm Water Checklist: No Exposure Certification

1. We have NO industrial materials (raw, finished, waste materials, and by-products)

or industrial-material handling equipment exposed to storm water on any part of

our facilitys property. (If you answer No then you need to be using either the

General Permit or the Individual Permit Checklist).

2. We have filed a No Exposure Certification for Exclusion from NPDES Storm Water

Permitting Form and the associated fee of $350.

3. We complete the Certification and submit it to our permitting authority once every

5 years along with the fee of $350. We note the date when we file so that we know

when we need to renew our certificate (assuming that the condition of no-exposure

continues to exist).

4. We submit a Certification for each separate facility or site we have that qualifies for

the no exposure exclusion.

5. If any changes at our facility result in industrial activities or materials becoming

exposed we understand that our no exposure condition ceases to be valid and we

apply for coverage under an applicable NPDES permit for storm water discharges

at least two days before the changes happen that cause the condition of exposure.

6. We understand that the no exposure certification form is non-transferable and that

if we take over a facility that we, as the new operators, must immediately complete

and submit a new form to claim the no exposure exclusion before beginning op-

erations. (If new operators fail to do this, the permitting authority will assume that

the facility is required to be covered under a storm water discharge permit.)

7. We have submitted a copy our completed certification to our Municipal Separate

Storm Sewer System (MS4) operator if they so request or require.

NPDES Storm Water Checklist: General Permit

1. We have industrial materials (raw, finished, waste materials, and by-products)

or industrial-material handling equipment exposed to storm water and we have

filed a Storm Water Notice of Intent (NOI) For Storm Water Discharges Associ-

ated With Industrial Activities Under The South Carolina NPDES General Permit

#SCR000000along with the first fiscal years annual operating fee of $75.

2. We have prepared and implemented a Storm Water Pollution Prevention Plan

(SWPPP) in accordance with the requirements of the general permit. Our SWPPP

includes the following items:

A. Best Management Practices (BMPs) we will use at our facility to control the

discharge of storm water. The BMPs are also designed to prevent and/or

minimize storm water exposure to pollutants and to provide sediment and

erosion control.

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No


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B. A description of yourPollution Prevention Team that includes which individual

or individuals within your facility are members of this team and are respon-

sible for developing the SWPP and assisting your facility or plant manager in

its implementation, maintenance, and revision. Individual responsibilities also

need to be identified.

C. A site map indicating an outline of the portions of the drainage area of each

storm water outfall that are within your facility boundaries, each existing

structural control measure to reduce pollutants in storm water runoff, surface

water bodies, locations where significant materials are exposed to precipita-

tion, locations where major spills or leaks have occurred, and the locations

of the following activities where such activities are exposed to precipitation:

fueling stations, vehicle and equipment maintenance and/or cleaning areas,

loading/unloading areas, locations used for the treatment, storage or disposal

of wastes, liquid storage tanks, processing areas and storage areas.

D. Aprediction of the direction of flow, and an identification of the types of pol-

lutants which are likely to be present in storm water discharges associated

with industrial activity for each area of your facility that generates storm water

discharges associated with industrial activity with a reasonable potential for

containing significant amounts of pollutants. Factors to consider include the

toxicity of chemical; quantity of chemicals used, produced or discharged; the

likelihood of contact with storm water; and history of significant leaks or spills

of toxic or hazardous pollutants. Flows with a significant potential for causing

erosion shall be identified.

E. A narrative description of the potential pollutantsources at the following

areas: loading and unloading operations; outdoor storage activities; outdoor

manufacturing or processing activities; significant dust or particulate generat-

ing processes; and on-site waste disposal practices. The description shall

specifically list any significant potential source of pollutants at the site and for

each potential source, any pollutant or pollutant parameter (e.g. biochemical

oxygen demand, etc.) of concerns shall be identified.

F. An inventoryof the types of materials handled at your facility that potentially

may be exposed to precipitation. Such inventory shall include a narrative

description of significant materials that have been handled, treated, stored or

disposed in a manner to allow exposure to storm water; method and location

of onsite storage or disposal; materials management practices employed to

minimize contact of materials with storm water runoff; the location and a de-

scription of existing structural and non-structural control measures to reduce

pollutants in storm water runoff; and a description of any treatment the storm

water receives.

G. A list of significant spills and significant leaks of toxic or hazardous pollut-

ants that occurred at areas that are exposed to precipitation or that otherwise

drain to a storm water conveyance at your facility.

H. A summary of existing discharge sampling data describing pollutants in storm

water discharges from your facility.

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No


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I. A description of storm water management controls appropriate for your facil-

ity. This needs to address the following minimum components, including a

schedule for implementing these controls: good housekeeping, preventive

maintenance, spill prevention and response procedures, inspection, em-

ployee training, record keeping and internal reporting procedures, non-storm

water discharges, sediment and erosion control, and management of runoff.

J. The plan includes a certification signed by the appropriate company official

that the facilitys discharge has been tested or evaluated for the presence of

non-storm water discharges. The certification must identify potential sources

of non-storm water at the site, a description of the results of any test and/or

evaluation, the criteria or method used, the date tested or evaluated, and the

drainage points evaluated.

K. Additional requirements for industries subject to Form R reporting under

SARA Title III, Section 313: In areas where Section 313 water priority chemi-

cals are present, appropriate containment, drainage control, and/or diversion-

ary structures shall be provided. In addition these areas must be operated

and maintained in a manner to minimize discharges of these chemicals to

the environment. Appropriate security and training must also be provided to

prevent the accidental or intentional release of water priority chemicals. The

SWPPP for a facility subject to the Form R reporting requirements must con-

tain a discussion of the measures taken to conform to the additional require-

ments and must be reviewed and certified by a South Carolina Registered

Professional Engineer once every three years and after significant modifica-

tions are made to the facility.

3. We retain our SWPPP on-site and it is signed by the appropriate company official.

We have also checked to see if our plan requires the signature of a Professional

Engineer and have had it signed by one if it is needed.

4. We periodically perform self-inspections to make sure that we are in compliance

with our permit. This includes inspecting our BMPs. We document these inspec-

tions and keep the records on site with our SWPPP.

5. Any deficiencies that we note in our inspections are corrected as soon as possible.

6. We update our SWPPP as is necessary to address any deficiencies noted during

inspections.

7. We have a Comprehensive Site Compliance Evaluation conducted at least once

per year by qualified personnel. We keep a report summarizing the scope of the

evaluation, personnel making the evaluation, major observations, and actions

taken as a part of our SWPPP.

8. We modify our SWPPP to address any deficiencies noted by the evaluation.

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No


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9. Some facilities are required to monitor their storm water discharge on either a

yearly or semiannual basis. For example, storage piles of solid chemicals used

as raw materials that are exposed to precipitation at facilities classified as SIC 30

(Rubber and Miscellaneous Plastics Products) or SIC 28 (Chemicals and Allied

Products) require annual storm water monitoring. We know and understand what

our facilitys monitoring requirements are and complete them as necessary.

10. We submit documentations of inspections, yearly Comprehensive Site Compliance

Evaluation, sampling results and etc. to the Bureau of Water if they so request.

11. Our facility operator completes and submits a Notice of Termination (NOT) form to the

appropriate NPDES permitting authority if we need to discontinue permit coverage.

We know that we will need to keep our SWPPP (and all of the records that are a part

of it) for at least one year after our permit is terminated.

NPDES Storm Water Checklist: Individual Permit

1. We have filed for a General Permit and been informed that we are required to obtain

NPDES storm water coverage under an individual permit. We have worked out the

requirements of this permit with the Bureau of Water.

2. We understand the requirements of our individual permit and have ensured that we

meet all of these requirements.

3. We know whom to contact if we have any questions or concerns about our individual

permit.

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No


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EPA Definition of No Exposurein Storm Water Permitting

No exposure means all industrial materials and activities are protected by a stormresistant shelter to prevent exposure to rain, snow, snowmelt and/or runoff.

Industrial materials and activities include, but are not limited to, material handlingequipment or activities; industrial machinery; raw materials, intermediate products, by-products, and final products; or waste products.

Material handling activities include storage, loading and unloading, transportationor conveyance, of any raw material, intermediate product, by-product, final product orwaste product.

Many final products which are meant to be used outdoors (e.g., automobiles)pose little risk of storm water contamination, i.e., the products cannot be mobilized byprecipitation or runoff, and are thus exempt from the requirement that these products be

sheltered to qualify for no exposure. Similarly, the containers, racks and other transportplatforms (e.g., wooden pallets) used for the storage or conveyance of these finalproducts can also be stored outside, providing the containers, racks and platforms arepollutant-free.

Storm-resistant shelters include completely roofed and walled buildings orstructures, as well as structures with only a top cover but no side coverings, providedmaterial under the structure is not otherwise subject to any run-on and subsequentrunoff of storm water.

EPA acknowledges there are circumstances where permanent, uninterruptedsheltering of industrial activities or materials is not possible. Under such conditions:

Materials and activities may be sheltered with temporary covers (e.g.,tarpaulins) until permanent enclosure can be achieved.

The no exposure provision does not specify every such situation, but NPDESpermitting authorities can address this issue on a case-by-case basis, i.e., determine ifthe temporary covers will meet the requirements of this section.

In general, EPA recommends that temporary sheltering of industrial materialsand activities only be allowed during facility renovation or construction.

1. Industrial Materials / Activities That Do Not Require a Storm Resistant ShelterWhile the intent of the no exposure exclusion is to promote a condition of permanent noexposure, a storm-resistant shelter is not required for the following industrial materials

and activities:

A. Drums, Barrels, Tanks and Similar Containers. Drums, barrels, tanks andsimilar containers that are sealed (sealed means banded or otherwise secured andwithout operational taps or valves), are not exposed provided those containers are notdeteriorated and do not leak. Unless the drums, barrels, etc., are opened while outdoors,or are deteriorated or leak, they will likely not constitute a risk of contaminating stormwater runoff. Consider the following in making your no exposure determination:


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- Containers can only be stored outdoors; any addition or withdrawal ofmaterial to / from containers while outdoors will not allow you to certify noexposure.

- Simply moving containers while outside does not create exposure.- Inspect all outdoor containers to ensure they are not open, deteriorated

or leaking. The EPA recommends that a designated individual regularly conduct

these inspections. Any time external containers are open, deteriorated orleaking, they must immediately be closed, replaced or sheltered.

-Containers, racks and other transport platforms (e.g., wooden pallets)used with the drums, barrels, etc., can be stored outside providing they arecontaminant-free.

B. Above Ground Storage Tanks (ASTs). In addition to generally beingconsidered not exposed, ASTs may also be exempt from the prohibition against addingor withdrawing material to / from external containers. ASTs typically utilize transfervalves to dispense materials that support facility operations (e.g., heating oil, propane,butane, chemical feedstocks) or fuel for delivery vehicles (gasoline, diesel, compressednatural gas). For ASTs to be operational and qualify for no exposure:

- They must be physically separated from and not associated with vehiclemaintenance operations.

- There must be no piping, pumps or other equipment leakingcontaminants that could contact storm water.

The EPA recommends, wherever feasible, that ASTs be surrounded by some type ofphysical containment (e.g., an impervious dike, berm or concrete retaining structure) toprevent runoff in the event of a structural failure or leaking transfer valve. Note: anyresulting unpermitted discharge would violate the CWA.

C. Lidded Dumpsters. Lidded dumpsters containing waste materials, providingthe containers are completely covered and nothing can drain out holes in the bottom, oris lost in loading onto a garbage truck. Industrial refuse and trash that is storeduncovered, however, is considered exposed.

D. Adequately maintained vehicles, such as trucks, automobiles, forklifts, trailersor other general-purpose vehicles found onsitebut not industrial machinerythat arenot leaking or are otherwise a potential source of contaminants.

- Vehicles passing between buildings will likely come into contact withprecipitation at some time, but so long as they are adequately maintained theywill not cause a condition of exposure. Similarly, non-leaking vehicles awaitingmaintenance at vehicle maintenance facilities are not considered exposed

-The mere conveyance between buildings of materials / products thatwould otherwise not be allowed to be stored outdoors, does not create acondition of exposure, provided the materials / products are adequately protectedfrom precipitation and could not be released as a result of a leak or spill.

E. Final products built and intended for use outdoors (e.g., new cars), providedthe final products have not deteriorated or are otherwise a potential source ofcontaminants. Types of final products not qualifying for a certification of no exposure:


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- Products that would be mobilized in storm water discharges (e.g., rocksalt).

- Products which may, when exposed, oxidize, deteriorate, leak orotherwise be a potential source of contaminants (e.g., junk cars; stockpiled trainrails).

- Final products which are, in actuality, intermediate products.

Intermediate products are those used in the composition of yet another product(e.g., sheet metal, tubing and paint used in making tractors).

-Even if the intermediate product is final for a manufacturer and destinedfor incorporation in a final product intended for use outdoors, these products arenot allowed to be exposed because they may be chemically treated or areinsufficiently impervious to weathering.

2. Other Potential Sources of ContaminantsA. Particulate Emissions From Roof Stacks and/or Vents. As stated in the Phase

II regulation, particulate emissions from roof stacks / vents do not cause a condition ofexposure, provided they are in compliance with other applicable environmental

protection programs (e.g., air quality control programs) and do not cause storm watercontamination. Deposits of particles or residuals from roof stacks / vents not otherwiseregulated and which could be mobilized by storm water runoff, are considered exposed.Exposure also occurs when, as a result of particulate emissions, pollutants can be seenbeing tracked out or carried on the tires of vehicles.

B. Acid Rain Leachate. As affirmed by a recent Environmental Appeals Boarddecision against the General Motors Corporation, CPC-Pontiac Fiero Plant (CWAAppeal No. 96-5), industrial facilities are also responsible for storm water dischargeswhich contain pollutants resulting from the leaching effect of acidic precipitation on metalbuilding structures. Therefore, operators must be aware when they attempt to certify acondition of no exposure of the existence of structural elements that could be soluble as

a result of contact with precipitation (e.g., uncoated copper roofs). If the dissolved metalsor other contaminants could cause or contribute to a water quality violation, a conditionof no exposure cannot be certified.

C. Pollutants Potentially Mobilized by Wind. Windblown raw materials cause acondition of exposure. This is to alert operators to situations where materials shelteredfrom precipitation can still be deemed exposed if the materials can be mobilized by wind.

Please be aware that even if you certify no exposure, your NPDES permitting authoritycan still require you to apply for an individual or general permit if it has determined thatyour discharge is contributing to the violation of, or interfering with the attainment ormaintenance of, water quality standards, including designated uses.


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NPDES Storm Water DischargesAssociated with Industrial Activities

Who should obtain an NPDES permit for storm water discharges associated withindustrial activity?

There are eleven industrial categories that are deemed to have storm waterdischarges associated with industrial activity and which require NPDES permitsfor such discharges:

Category I: Industries subject to storm water effluent limitationsguidelines, new source performance standards, or toxic pollutanteffluent standards under 40 CFR subchapter N (except industries withtoxic pollutant effluent standards which are exempted under category(X). These types of activities include the following:

Dairy Products processingGrain MillsCanned & Preserved Fruits and Veg. Processing *Canned & Preserved seafood processingBeet, Crystalline & Liquid cane sugar refiningTextile MillsCement ManufacturingFeedlotsOrganic Chemicals plastics and synthetic fibersInorganic Chemical Manufacturing*Soap and Detergent Manufacturing

Fertilizer ManufacturingPetroleum RefiningIron and Steel ManufacturingNonferrous Metal ManufacturingPhosphate Manufacturing*Steam Electric PowerFerroalloy Manufacturing *Leather Tanning and FinishingGlass Manufacturing *Asbestos ManufacturingRubber Manufacturing

Timber Products ProcessingPulp, Paper and Paperboard *Builders paper and board MillsMeat ProductsMetal FinishingCoal Mining *Mineral Mining & Processing *Pharmaceutical Manufacturing*


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Ore Mining & Dressing *Paving and Roofing MaterialsPaint FormulatingInk FormulatingPesticide Chemicals *

Carbon Black ManufacturingBattery ManufacturingPlastic Molding and FormingMetal Molding and CastingCoil CoatingPorcelain EnamelingAluminum FormingCopper Forming *Electrical & Electronic ComponentNonferrous Metal Forming & Powders

* some facilities in group do not have limits or standards, see40 CFR subchapter N to verify.

Category II: Industries considered to be heavy manufacturers:SIC Code 24: Lumber and wood products (except 2434 -wood and kitchen cabinets).SIC Code 26: Paper and allied products (except 265 paperboard containers and boxes and 267 convertedpaper and paperboard products, except containers andboxes).SIC Code 28: Chemical and allied products (except drugs).SIC Code 29: Petroleum and coal products.SIC Code 311: Leather tanning and finishing.SIC Code 32: Stone, clay, glass, and concrete products(except 323 glass products made of purchased glass).SIC Code 33: Primary metal industries.SIC Code 3441: Fabricated structural metal.SIC Code 373: Ship and boat building and repair.

Category III: Mineral Industries with SIC codes of 10 14 (includingactive and inactive mining).

Category IV:Hazardous waste treatment, storage, or disposalfacilities, including those that are operating under interim status or apermit under subtitle C of RCRA.

Category V: Landfills, land application sites, and open dumps thathave received any industrial waste from any of the other ten


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Categories including those that are subject to regulation under subtitleD of RCRA.

Category VI: Facilities involved in the recycling of materials, includingmetal scrap yards, battery reclaimers, salvage yards and automobile

junkyards, including, but limited to those classified as SIC 5015 (motorvehicle parts, used) and SIC 5093 (scrap and wastes material-thisincludes auto wreckers engaged in dismantling automobiles for scrap).

Category VII: Steam electric power generating facilities, includingcoal handling sites.

Category VIII: Transportation facilities which have vehiclemaintenance shops, equipment cleaning operations, or airport de-icingoperations and which have Standard Industrial Classification Codes as

follows:SIC Code 40: Railroad Transportation.SIC Code 41: Local and inter-urban passenger transport.SIC Code 42: Trucking and warehousing (except 4221 farmproduct warehousing and storage, 4222 refrigerated warehousingand storage, and 4225 general warehousing and storage).SIC Code 43: U.S. Postal Service.SIC Code 44: Water transport.SIC Code 45: Transport by air.SIC Code 5171: Petroleum bulk stations and terminals (exceptservice stations or facilities that sell only packaged products).

Category IX: Treatment works treating domestic sewage or any othersewage sludge or wastewater treatment device or system, used in thestorage, treatment, and reclamation of municipal or domestic sludge,including land dedicated to the disposal of sewage sludge that islocated within the confines of the facility, with a design flow of 1.0 mgdor more, or required to have an approved pretreatment program underfederal regulations.

Category X: Construction activity including clearing, grading andexcavation activities except: operations that result in the disturbance ofless than one acre of total land area which are not part of a largercommon plan of development or sale.

Category XI: Light manufacturing facilities having the following SICCodes:

SIC 20: Food and kindred products.SIC 21: Tobacco products.SIC 22: Textile mill products.


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SIC 23 : Apparel and other finished products made fromfabrics and similar material.SIC 2434: Wood kitchen cabinets.SIC 25: Furniture and fixtures.SIC 265: Paperboard containers and boxes.

SIC 267: Converted paper and paperboard products, exceptcontainers and boxes.SIC 27: Printing, publishing, and allied industries.SIC 283: Drugs.SIC 285: Paints, varnishes, lacquers, enamels, and alliedproducts.SIC 30: Rubber and miscellaneous plastic products.SIC 31: Leather and leather products, except 311 leathertanning and finishing.SIC 323: Glass products made of purchased glass.SIC 34: Fabricated metal products, except 3441

Fabricated structural metal products.SIC 35: Industrial and commercial machinery and computerequipment.SIC 36: Electronic and other electrical equipment andcomponents, except computers.SIC 37: Transportation equipment, except 373 ship andboat building and repair.SIC 38: Measuring, analyzing, and controlling instruments;photographic, medical and optical goods; watches andclocks.SIC 39: Miscellaneous manufacturing facilities.SIC 4221: Farm product warehousing and storage.SIC 4222: Refrigerated warehousing and storage.SIC 4225: General warehousing and storage.

Exclusions from the permit requirements based on no exposure.

All except category X (Construction Activity) can be exempted from permitrequirements if they certify to the Department that there is no exposure tostorm water of industrial materials (raw, finished, waste materials and by-products) or industrial-material handling equipment.


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Introduction of the Self Operationand Maintenance Evaluation Surveyfor Publicly Owned Treatment Works (POTWs)

The successful operation of a POTW depends on compliance with therequirements of the NPDES permit issued by DHEC for the water being releasedto South Carolinas environment. However, the manner in which the POTWsmanagement, operations, and maintenance are performed may effect thesustained successful operation of a POTW. This survey, a product of DHECsBOW and CWM, with input from private industry, is intended to help identifyareas of management, operations, and maintenance that need to be addressedto avoid future environmental problems at POTWs.

This survey covers GENERAL considerations of a POTW, including, financialobligations, system integrity, and maintenance practices as well as its public

outreach program. PLANT-SPECIFIC concerns include staffing certifications,treatment efficiencies, sludge management, and plant physical characteristics.The answer to each question is weighted to reflect a large value for a lessdesirable response (one that may lead to a future environmental concern) and asmall value for a more desirable answer (one that will be less likely to lead tofuture environmental concerns). The cumulative value of the answers may bewell within the Green zone, indicating a healthy over-all program, but containanswers to specific questions that fall in the Yellow or Red zones that shouldbe addressed to help avoid future problems.

Other surveys are being developed that review non-POTW discharges ofwastewater to the environment covered by NPDES permits (industrialwastewater NPDES holders), and Drinking water systems with ground watersources. These will be incorporated in this publication as they are approved.


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Self Operation and Maintenance Evaluation Survey

for Publicly Owned Treatment Works(issue 10-26-06)

GENERAL

TrainingHow many hours does your facility require annually per employee forcontinuing education programs that include environmental training?6 or more = (0); 4-6 = (2); 0-4 = (4).

FinancialWhat portion of the revenues generated by your facility is used to supportthe wastewater treatment program?60-100% = (0); 20-60% = (2); 0-20% = (4).

Do you have adequate funding to operate the WWTF for the foreseeablefuture? YES = (0); NO = (6).

Do you budget for replacement equipment? YES = (0); NO = (2).

Do you have a plan to finance future expansion of your plant? YES = (0);NO = (2).

PretreatmentDo you have industrial users of your WWTF? YES = (2); NO = (0).

If YES, do you issue permits defining the strength and flow of theirdischarge to your system? YES = (0); NO = (6).

What fraction of your influent is contributed by the industries?0-10% = (0); 11-25% = (2); 26-50% = (4); > 50% = (6).

Inflow and InfiltrationHow many times per year has your daily flow exceeded twice the designdaily flow?0 = (0); 1-2 = (2); 3 or more = (4).

How many times in the past year have there been overflows at theWWTF?0 = (0); 1 = (4); 2 or more = (8).

What is the length of your WWTFs collection system? ______ = A miles.


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A divided by 100 = B (hundred miles of collection system).How many overflows have occurred in this collection system during thepast year? ______ = C.Overflows per 100 miles = C divided by B = N.If N = 0-3, then (0); if N = 4-10, then (2); if N = over 10, then (8).

Do you routinely smoke test, dye test, or televise the sewer system forleak detection? YES = (0); NO = (2).

Preventive MaintenanceAre there written instructions that are followed for the operation of theWWTF? YES = (0); NO = (6).

Are there written instructions that are followed for the maintenance

(including preventive maintenance) of the WWTF? YES = (0); NO = (6).

Are there written instructions that are followed for the operation of thecollection system of your facility? YES = (0); NO = (6).

Are there written instructions that are followed for the maintenance(including preventive maintenance) of the collection system of yourfacility? YES = (0); NO = (6).

Are permanent records of all operations and maintenance proceduresmaintained to enable future problems to be assessed and addressedoptimally?Yes = (0); No = (6).

Public OutreachIs there some form of formal community outreach and public education atyour WWTF? YES = (0): NO = (10).

Total Points for General Section: _____.

Green Zone = 0-19; Yellow Zone = 20-46; Red Zone = 47-94.


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PLANT-SPECIFIC

StaffDo you meet permit requirements for certified operators?YES = (0); NO = (10).

Is there appropriate coverage on-site at all times? YES = (0); NO = (5).

Impurity ReductionAverage influent TSS concentration = _____ PPM = A.Average effluent TSS concentration = _____ PPM = B.[(A-B)/A] X 100 = _____ %.>95% = (0); 85-94% = (1); 80-84% = (2); 75-79% = (3); 95% - (0); 85-94% = (1); 80-84% = (2); 75-79% = (3); 95% = (0); 85-94% = (1); 80-84% = (2); 75-79% = (3);


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90% = (5).

Does your WWTF meet all the metal limits in the NPDES Permit? N/A =(0); YES = (0); NO = (5).

Does your WWTF meet all the nutrient limits in the NPDES permit?N/A = (0); YES = (0); NO = (5).

Sludge HandlingDoes your WWTF have an established process control program for sludgeacceptability?

YES = (0); NO = (10).Can operators interpret the process control test results and make soundoperational decisions based on these interpretations?

YES = (0); NO = (10).

Are test results from the process control program the basis of the sludgeacceptability?YES = (0); NO = (10).

Are there any bottlenecks in your sludge handling process?YES = (1); NO = (0).

Please specify how the sludge generated by your WWTF is handled.____________________________________________________________________________________________________________________________________________________________________________________

How long can you continue to handle the sludge in this manner, givenyour current funding sources?36 months or more = (0), 24-35 months = (1), 12-23 months = (2), 6-11months = (3), 3-5 months = (4), 12 months = (4).

Have beneficial uses for the sludge generated by your WWTF beenconsidered?YES = (0); NO = (2).


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Groundwater MonitoringDoes your WWTF have an unlined lagoon?YES = (7); NO = (0).

If YES, does your WWTF monitor groundwater?

YES = (0); NO = (7).

Plant By-PassesIs your WWTF capable of a complete by-pass?YES = (7); NO = (0).

Operation StrategyIf your WWTF is not manned 24 hours per day, 7 days per week, is thereequipment to notify staff of the following plant problems?

_____ Low pH._____ Power Failure.

_____ Low/High Water Level._____ Monitoring Equipment Failure.

If number of choices selected is:0 = (4).1 = (3).2 = (2).3 = (1).4 = (0)

Emergency GeneratorsDoes your facility have any emergency generators?YES = (0); NO = (7)

If YES, is the generator(s) been exempt from air quality permitting (lessthan 150 KW rated capacity or operated less than 250 hours per year witha record showing hours used) or permitted by SC DHEC Bureau of AirQuality?YES or N/A = (0); NO = (7).

Facility AgeHow long has it been since the last major up-grade of your WWTF?0-5 yrs. = (0); 6-19 yrs. = (5); 20 or more yrs. = (10).


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Disinfection MethodDoes this facility disinfect treated effluent by (chose one):

Contact with chlorine/SO2? _____ (3).Contact with sodium hypochlorite/SO2?

Sodium hypochlorite purchased in bulk _____ (2).

Sodium hypochlorite generated from brine _____ (1).Exposure to ultraviolet radiation? ______ (0).

ComplianceHas your facility been in Significant Non-Compliance during the past twoyears?

YES = (10); NO = (0).

Total Points for Plant-Specific Section: _____.Green Zone: 0-30; Yellow Zone: 31-73: Red Zone: 74-147.


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GRADING SYSTEM

Point Summation Page

No. of Zones

General System Questions Green Yellow Red Actual ValuesTraining 1 0 2 4 ___________Financial 4 0-2 3-6 7-14 ___________Pretreatment 3 0-3 4-6 7-14 ___________Inflow/Infiltrn 4 0-4 5-10 11-22 ___________Maintenance 5 0-6 7-14 15-30 ___________Public Outreach 1 0 10 ___________

Sub-Total ___________

Plant-Specific

Staff 2 0 5 10-15 ___________Impurity Reduction 3 0-3 4-7 8-15 ___________Effluent 6 0-6 7-14 15-30 ___________Sludge Handling 7 0-8 9-20 21-42 ___________Ground Water Mntrng. 2 0 7 14 ___________Plant By-Pass 1 0 7 ___________Operation 1 0-1 2 3-4 ___________Generators 2 0 7 ___________Age 1 0 5 10 ___________Disinfection method 1 0 1-2 3 ___________Compliance 1 0 10 ___________

Sub-Total ___________

FORM TOTAL ___________

General System0-19 Green Zone

20-46 Yellow Zone47-94 Red Zone

Plant-Specific0-31 Green Zone32-78 Yellow Zone79-157 Red Zone

Entire Form0-50 Green Zone51-125 Yellow Zone126-251 Red Zone


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ZONE DESCRIPTIONS

Green Zone, up to 20% of total points: The overall section/system is healthy;

however, there may be particular questions scoring in the yellow or red zone andshould receive closer review.

Yellow Zone, between 20 and 50% of the total points: One or more sectionsscored high (or a combination of mid-range to higher scores). These areasshould receive greater emphasis. There may be particular questions scoring inthe red zone which should receive prompt attention.

Red Zone, between 50 and 100% of the total points: One or more sectionsscored high (or a combination of higher scores) and have placed your system inwhat can be considered to be in danger of being in non-compliance. Identified

areas should be addressed promptly.

This survey is for the benefit of the facility completing it and not to be used as a sourceof regulatory information. Completing this survey does not assure compliance withenvironmental regulations and does not preclude enforcement actions as a result of

inspections performed independently of this survey.


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Air Quality Regulatory Requirements

Permitting and compliance with air quality regulations requires the evaluation of anumber of facility specific factors. The following table of processes covers the morecommon facility operations that may require an air permit and/or generate compliance

concerns.

AbrasiveBlasting

AsphaltProduction

BoatManufacturing

CabinetManufacturing

ChemicalProduction

CleaningProductProduction

CoatingsBurn-off

CoffeeRoasting

CollisionRepair

ConcreteProduction

CottonGinning

Cremation Cultured MarbleProduction

DryCleaning

Foundries

Fuel

Burning

Furniture

Production

Grain

Milling

Grinding Incineration

Ink/DyeProduction

LumberMilling

Machining MetalFabrication

Millwork

Mining Painting PlatingOperations

PrintingOperations

Recycling

ReinforcedFiberglassPlasticsProduction

RubberProcessing

SalvageOperations

TextileProcessing

WoodPreserving

If your facility encompasses any of these operations, and is a small business, contactthe Small Business Environmental Assistance Program (SBEAP) at DHEC (toll-free at800-819-9001) for assistance in determining your air permit status.

Small businesses may not have a clear understanding when to apply for a permit. Aconstruction permit is required before the construction, alteration, or addition to a sourceof air contaminants, including any device for the control of air contaminant discharges.The following discusses some of the conditions that may require air quality permits;however, air quality permits may also be required for other reasons. Contact the SBEAPfor technical permitting advice.

A Major Source has the potential to emit, before emission controls: 100 tons or more per

year of Criteria Pollutants; 10 tons or more per year of any single Hazardous AirPollutant, or 25 tons or more per year of combined Hazardous Air Pollutants. If there isthe potential to emit any single Toxic Air Pollutant at 1,000 pounds per month or more, aconstruction permit will be required; a construction may be required if less than 1,000pounds per month is emitted, depending on, among other considerations, the nature andamount of pollutant, location, proximity to commercial establishments and residences.See the SC DHEC Air Pollution Control Regulation No. 61-62.5, Standard No. 2 for adiscussion of Criteria Pollutants. See SC DHEC Air Pollution Control Regulation No. 61-62.5, Standard No. 8 for a discussion of Toxic Air Pollutants. See SC DHEC Air


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Pollution Control Regulation No. 61-62.63 for Hazardous Air Pollutants. Contact theSBEAP for potential to emit determinations. Go towww.scdhec.gov/eqc/baq/pubs/PermittingGuide-Industry.pdf for additional guidance.

Air construction/operating permits are required if . . .

. . . there is a boiler or hot water heater 1.5 million BTUs per hour heatinput or larger (larger than 35 HP).

. . . a process has a potential to emit more than 1.0 pound per hour ofuncontrolled particulate matter. If there is a control device, such as abaghouse or cyclone, which is needed to control these emissions, morethan these amounts, are likely.

. . . a process has a potential to emit more than 1,000 pounds per monthof volatile organic compounds. For paint usage, multiply the maximumgallons paint that can be used per month by the volatile organiccompound content from a MSDS to arrive at this figure.

. . . a process has a potential to emit more than 1,000 pounds per monthof toxic air pollutants. For paint usage, multiply the gallons of paint usedper month by each toxic air pollutant content (from the MSDS), plus anytoxic air pollutant solvents used.

No construction/operating permit is required for the following sources:

Boilers and space heaters less than 1.5 million BTUs per hour rated inputcapacity, burning a virgin fuel.

Comfort air-conditioning or ventilation systems.

Motor Vehicles.

Laboratory hoods.

Emergency power generators of less than 150 KW rated capacity, orthose that operate 250 hours per year or less and have a method torecord the actual hours of use, such as an hour-meter.

Sources emitting only steam, air, nitrogen, oxygen, carbon dioxide, or anyphysical combination of these.

Sources that need to be evaluated by DHEC to determine whether or not an air permit isrequired are listed below or an exemption can be granted. This evaluation will include,but not necessarily be limited to, the nature and amount of pollutants, location, proximityto residences and commercial establishments, etc.

Sources with uncontrolled particulate matter emission rates of less than 1.0pounds per hour and/or uncontrolled volatile organic compound emission rates ofless than 1,000 pounds per month.

Sources whose only emissions are fugitive emissions.
http://www.scdhec.gov/eqc/baq/pubs/PermittingGuide-Industry.pdfhttp://www.scdhec.gov/eqc/baq/pubs/PermittingGuide-Industry.pdf


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Air Regulatory Requirements Checklist

Because air permits tend to be very complex, this checklist is set up differently than the other checklists. This

checklist has been set up to just determine whether or not you may need an air permit. If you answer yes to any

of the following questions or statements, then there may be a chance that you need to have an air permit.

1. Do you have any air pollution control devices present on any process or equipment?

Some examples of these would be: scrubbers, baghouses, and cyclones.

2. Are any of the following fuel-burning sources present at your facility: boilers, furnaces,

incinerators, or other fuel-burning sources?

3. Do you use natural gas, fuel oil, propane or another type of fuel?

4. Do you have any storage vessels? Some examples of these would be silos and tanks.

5. Do you have any parts cleaning or degreasing equipment present at your facility?

6. Do you have any extractors present at your facility?

7. Do you have any reactors present at your facility?

8. Is there any distillation equipment at your facility?

9. Do you have any materials on-site in excess of 10,000 pounds?

10. Do you have stacks or vents that route process emissions to the outside air?

11. Do you have valves and flanges present in your process equipment?

If you answered yes to any of the above questions then you need to contact the Bureau of Air Quality at

(803) 898-4123 to determine if you need a permit or qualify for an exemption to come into compliance,

there is a list of additional information and Bureau contacts at the end of this section.

Yes No/NA

Yes No/NA

Yes No/NA

Yes No/NA

Yes No/NA

Yes No/NA

Yes No/NA

Yes No/NA

Yes No/NA

Yes No/NA

Yes No/NA


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Underground Storage Tanks Regulatory Requirements

An Underground Storage Tank (UST) is any tank, including the connected undergroundpiping, whose volume is 10% or more beneath the surface of the ground that is used, orhas been used, to store a regulated substance. These substances include liquid

petroleum (but not propane) or certain hazardous substances. Some oil/waterseparators are also subject to UST requirements.

Underground Storage Tank regulations require owners and operators to provide spill andoverfill prevention, corrosion protection, release detection, management practices,equipment standards, cleanup requirements for leaks, and financial responsibility. Theregulations are in place to prevent the contents of the tank from being released into theenvironment and contaminating groundwater (the source of drinking water for manyAmerican households and businesses).


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UST Checklist

If you answer Yes or N/A to ALL of the questions in this section then you are on the right track to being in com-

pliance. However, if you answer No to ANY of the questions you may not be complying with all of the require-

ments under South Carolina and Federal Environmental Laws and Regulations. If you need help determining how

to come into compliance, there is a list of additional information and Bureau contacts at the end of this section.

1. An UST of 1,100 gallons or less capacity that is used exclusively for farm or

residential motor fuel does not have to be registered. Also, USTs storing heating

oil used exclusively for on-site consumption do not need to be registered. All other

USTs, both in-use and out-of-service, must be registered.

All of our USTs that require it are registered with the state.

2. All new USTs must be permitted. The UST owner must first obtain a Permit to

Install prior to installing the system. A Permit to Operate must be obtained after

installation, but before operating the system. A Permit to Operate is valid for the

life of the system.

All of our registered USTs have the required permits with the state.

3. Annual registration fees are assessed for both in-service and out-of-service

USTs. There is an annual registration fee of $100 per UST. The UST owner or

operator must display a registration certificate at the site where the UST is located.

The registration certificate is valid for one year and is issued when the annual fees

are paid.

Our company has paid the annual registration fee for our UST(/s) and posted

the registration certificate as required.

4. We have the necessary spill prevention measures in place and they are opera-

tional. This includes a spill bucket that does not have any cracks or holes and a

drain mechanism that is not broken or impaired by debris. (Spill prevention is not

required for USTs in proper temporary closure or that never receive deliveries of

more than 25 gallons.)

5. We have an appropriate overfill prevention device (such as a flapper valve, an

alarm, or a ball float valve) in place and it is operational. (Overfill prevention is not

required for USTs in proper temporary closure or that never receive deliveries of

more than 25 gallons.)

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No


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6. Corrosion protection systems must protect the buried tank and any metal piping

components (such as swing joints, flex-connector, and etc.) that are not isolated

from the soil. We have a corrosion protection system in place that is operated and

maintained to provide continuous protection and it has been tested in the last three

years (corrosion protection must be maintained on USTs in temporary closure).

OR

We have a system for which corrosion protection is not required and we have

records available to document this fact.

7. We inspect any UST systems with impressed current cathodic protection every 60

days and record the rectifier readings.

8. Any of our tanks that are lined are inspected internally within 10 years of installa-

tion of the lining and every 5 years thereafter.

9. All tanks that contain hazardous substances are double-walled.

10. IF any tanks or piping undergo structural repairs:

A. The system is internally inspected after the repair OR monitored for releases

using a monthly monitoring method OR the system is tested using another

approved method.

B. The system was tightness tested within 30 days of the completion of the

repair.

C. IF the repairs were made to a cathodically protected UST, corrosion protec-

tion systems were tested and/or inspected within 6 months of the repair.

D. We keep records of all UST system repairs for the operating life of the UST

system.

11. All of our USTs have been equipped with a permissible method of release detec-

tion that is able to detect a release from any portion of the UST system that rou-

tinely contains product. This release detection system is operational and meets

the necessary performance standards.

12. Our tanks and piping are monitored monthly for releases and we have the re-

cords of this available (at a minimum, we have records for the past 12 months of

operation).

13. Designated employees are familiar with applicable release reporting procedures.

14. We have reported our financial responsibility mechanism.

15. We notified the UST Program at least 30 days prior to the permanent closure

date of any UST and keep site assessment results for 3 years.

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No

Yes/NA No


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Solid and Hazardous Waste Regulatory Requirements

The term solid waste can be slightly confusing. Despite the word solid in its label,solid waste actually refers to any garbage, refuse, sludge, or other discarded materialincluding solid, liquid, semi-solid, or contained gaseous materials. If any of theses items

are bi-products of the processes at your facility, then you need to make sure that you areproperly disposing of them.

The first thing that you need to do to properly dispose of solid waste is to determine if itis hazardous or not. Hazardous wastes have special disposal requirements that arediscussed in the next section. Some wastes that are not regulated hazardous wastesstill require special methods of disposal. These wastes are termed special wastes andare discussed below. If a solid waste is determined to be neither hazardous nor special,then it may be placed in one of three types of landfills depending on the characteristicsof the waste. If you have any questions or concerns about your solid wastes pleasecheck with your regulatory authority about its proper disposal method.

Construction and Demolition/Land Clearing Debris Landfill:A Construction and Demolition (C & D) Landfill is for, as the name implies, constructionand demolition debris. Beneficial fills must be separated out of debris gong to a C & Dlandfill. Shrubs, brush, tree remains, and other materials generated by operations toprepare land for development should go to a Land Clearing Debris Landfill.

Industrial Landfill:There are three categories of Industrial Landfills. The breakdown is based on themaximum contamination level for drinking water of the various contaminants that areincluded in a Toxicity Characteristic Leaching Procedure (TCLP). A Category I IndustrialLandfill can have leachate that contains up to ten times the maximum contaminant level(MCL) from the TCLP. The leachate from a TCLP for a Category II is from ten to thirtytimes the MCL and Category III can be up to thirty times the MCL.

Municipal Solid Waste Landfills:Municipal Solid Waste Landfills are for other non-hazardous, solid wastes that have aliquid content sufficient to pass the Apaint Filter A Test with the exception of: used motoroil, white goods, lead/acid batteries, yard wastes and land clearing debris, and wholetires. These exceptions have special requirements for disposal.

Used motor oil must be label Used Oil before it is recycled, re-refined, or reused.White goods need to have their hazardous components removed and then the metalcontent should be recycled. Lead/Acid batteries must be recycled by a licensed facilityto recover component materials. Yard wastes and land clearing debris must becomposted or otherwise beneficially used. They can also be placed in a Land ClearingDebris Landfill. Whole tires should be recycled for their energy content, ground andrecycled for their rubber value, or cut into eighths before being placed in a landfill.

Special Wastes

Special wastes are solid wastes that are not regulated hazardous wastes but are stilldifficult or dangerous to handle and require unusual management by the landfill. Thesespecial wastes include, but are not limited to:


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pesticide wastes

liquid wastes or bulk liquid wastes

sludges

industrial process wastes of cutting oils, chemical catalysts, distillation bottoms,etching acids, equipment cleanings, paint sludges, core sands, metallic orasbestos dust, and contaminated or recalled wholesale or retail products

waste from a pollution control process

residue or debris from the clean up of a spill or release of chemical substances

materials that contaminated from the cleanup of a facility or site formerly used forthe generation, storage, treatment, reclamation, or disposal of listed wastes

containers and drums

Special wastes, such as the ones above, cannot be accepted by a municipal wastelandfill without prior written approval by the disposal facility in accordance with DHECregulat

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